Dear Colleagues on the Board of Audiology & Speech-Language Pathology,

Thank you for providing a forum for concerned professionals to provide input regarding the regulation of speech-language pathology assistants (SLPAs) in the Commonwealth of Virginia. The regulation of the qualifications necessary to become a SLPA and the way in which licensed speech-language pathologists (SLPs) supervise and work with the SLPAs has tremendous ramifications for our profession. More importantly, careful regulation is necessary to ensure the safety and wellbeing of the people we provide our services to.  

The call for public comment requested input about ideas that need to be considered during the development of the practice of assistant speech-language pathologist proposal.  As regulations are considered, please consider the following ideas:

• The educational requirements and training required to become a SLPA must be clearly stipulated. Post high school, specialized training must be a requirement for hire and licensure as a SLPA. As you know, the minimum requirements for being a licensed SLP are a master’s degree and the accrual of clinical experiences across a variety of domains. If a SLPA is going to effectively assist the SLP without causing harm, specialized training in the area that the SLPA is going to practice is necessary.
• As others have stated, the specific regulations regarding the supervising SLP must specify minimum percentage, or number of hours, per week that each SLPA must be supervised as well as the proportion of therapy sessions for each client that must be conducted by the licensed SLP. Please see Dr. Hoffman’s comments on this. 
• Employers should not be able to place SLPAs with SLPs who have less than 2 years of experience following the completion of the requirements for national certification.Additionally, the supervising SLP should have coursework or continuing education credits specific to supervision practices prior to becoming a supervisor for a SLPA.
• In order to protect the public and the supervising SLP, the diagnostic profile of clients the SLPA can treat should be specified to exclude medically fragile individuals.
• As Dr. Hoffman indicated, ethical considerations need to be addressed regarding the potential conflicts that may arise for supervising SLPs relative to their employers, and the individual SLPAs they are asked to supervise.

The inclusion of SLPAs in the everyday practice within the field of speech-language pathology has the potential to improve the quality of the services that SLPs provide by allowing more concentrated care. Conversely, without vigilant attention to the structure of the scope of practice for the SLPA the potential for harm to come to the people who need us the most is profound.

We are grateful for your careful consideration of the regulatory actions that will protect us, the licensed SLPs, and most importantly the people of the Commonwealth whom we serve.